Florida Department of Environmental Protection

Florida Department of Environmental Protection

Florida Department of Environmental Protection Joe Panetta, Environmental Specialist IIIAir Resource ManagementSouthwest District OfficeSeptember 30, 2010

Workshop for Perchloroethylene (Perc) Dry Cleaner

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2IntroductionsMara NascaAir Program Administrator

Danielle D. HenryAir Compliance Manager

Cindy FalandyszAir Enforcement Manager

Joe PanettaAir Program Environmental Specialist III

3Outline

How Dry Cleaning was Discovered

Perchloroethylene (PERC) dry cleaning facility requirements per Rule 62-213.300(1) (a), Florida Administrative Code, (F.A.C.)

Health Effects from Perc

Registration Requirements in DEP Form No. 62-213.300(1)(a), F.A.C.

(Code of Federal Regulation) 40CFR 63.320

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Southwest District Air

Program has

Approximately 40 Perc

Dry Cleaner Facilities that are registered

with an Air General

Permit

5Rule 62-210.310(1) (a), Florida Administrative Code, (F.A.C.)

PERCHLOROETHYLENE (PERC) DRY CLEANER Requirements** Additional Rules may be required by Hillsborough, Pinellas and Sarasota Counties 5Dry Cleaning

63.321 Definitions.

Dry cleaning means the process of cleaning articles using perchloroethylene.Definition6

Dry cleaning came about by accident. In 1855, Jean Baptiste Jolly, a French dye-works owner, who noticed that his tablecloth became cleaner after his maid spilled kerosene (paraffin) on it. He later developed a service cleaning people's clothes in this manner, which became known as "nettoyage sec," or "dry cleaning.Perchloroethylene (PERC) Dry Cleaning7

Doing laundry has been a common household activity for years. Whether the technology was beating the garments on rocks by the river or pushing buttons on programmed washing machines, this process depends on water and a mechanical action usually assisted by soap or an alkali. The purpose of an alkali is to saponify the oils and dislodge ordinary soil and other matter. More often than not, the soapy agent holds soil in suspension as it becomes loose during the wash cycle, and is subsequently flushed away during the rinse cycle and centrifugal spin.

The drying process for doing laundry at home is either hanging clothes on a clothesline or tumbling them in a gas- or electric-heated dryer. Perchloroethylene (PERC) Dry Cleaning8

Dry cleaning, on the other hand, is different. It's a process that cleans clothes without water. The cleaning fluid that is used is a liquid, and all garments are immersed and cleaned in a liquid solvent -- the fact that there is no water is why the process is called "dry.

Perchloroethylene (PERC) Dry Cleaning9

Early dry cleaners used a variety of solvents including gasoline and kerosene to clean clothes and fabrics. In the United States, the dry-cleaning industry is fairly new and has developed only during the past 75 years. Since World War II ended, the volatile synthetic solvents carbon tetrachloride and trichlorethylene gave way to a product known as perchlorethylene (perc), which became the overwhelming solvent choice for the industry. It was not only safer and faster, but did a much better job of cleaning, required less massive equipment, less floor space, and could be installed in retail locations offering excellent quality one-hour service.


As a result of this innovation, the majority of clothes today are cleaned by perc. A proliferation of cleaning franchises and dry-cleaning businesses offering fast service from convenient, clean, and attractive locations evolved to change the industry into what we see today.


Perc is classified as a hazardous air contaminant by the United States Environmental Protection Agency and must be handled as a hazardous waste. To prevent it from getting into drinking water, dry cleaners that use perc must take special precautions against site contamination. Landlords are becoming increasingly reluctant to allow dry cleaners to operate in their buildings. When released into the air, perc can contribute to smog when it reacts with other volatile organic carbon substancesPerchloroethylene (PERC) Dry Cleaning-Health Effects12

Perc is readily absorbed into the bloodstream both through inhalation and after oral exposure. Dermal uptake appears to be complete but slower than other routes of exposure.

From the bloodstream, perc distributes readily into fatty tissues and some accumulate there.

Perc also crosses the placental barrier.

Perc is mostly exhaled unchanged. Regardless of the route of exposure, 1-3% of the absorbed PERC is metabolized.

Perchloroethylene (PERC) Dry Cleaning-Health Effects13The primary route of exposure to PERC is inhalation.

Perchloroethylene (PERC) Dry Cleaning-Health Effects14

Once taken into the body, some perc can be excreted through exhalation or (after metabolization) through urine.

Metabolized into TCA trichloroacetictrichloroaceticacid

Perchloroethylene (PERC) Dry Cleaning-Health Effects15

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16Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsWhat is the purpose of the

Perchloroethylene Dry Cleaner Air

General Permit Notification Form?

17Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsThe use of an Air General Permit notification form serves a several purposes:

Provides notice to the Department that the facility is in operation and

Prescribes the requirements under which the facility is allowed to operate

[Rule 62-296.310(5)(b), F.A.C.]

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Who is Eligible to use the

Perchloroethylene (Perc) Dry Cleaning

Air General Permit?Perchloroethylene (PERC) Dry Cleaning - Rule Requirements

19A perchloroethylene dry cleaning facility may use a air general permit provided the: facility meets the eligibility criteria set forth in the rule and, throughout the term of the general permit

maintains its eligibility to use the general permit and complies with all terms and conditions of the general permit.

The responsible official of the perchloroethylene dry cleaning facility shall determine the facilitys eligibility for the Air General Permit and notify the Department of intent to use the Air General Permit .

Rule 62-213.300(1)(a), F.A.C.Perchloroethylene (PERC) Dry Cleaning - Rule Requirements

20Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsA perchloroethylene dry cleaning facility is eligible to operate under the terms and conditions of the Air General Permit established at Rule 62-213.300(1)(a), F.A.C.,

provided the responsible official has submitted a completed Part III of this notification form to the Department at least 30 days prior to beginning operations under the general permit

and throughout the term of the general permit, all of the following conditions are met:

21Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsThe facility operates no emissions units other than perchloroethylene dry cleaning systems and emissions units which are considered insignificant pursuant to the criteria of Rule 62-213.300(2)(a)1., F.A.C., set forth in paragraph (1)(b);

The facility is classified as a small or large area source pursuant to 40 CFR Part 63, and

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Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsThe facility complies with all general conditions of Rule 62-213.300(3)

23Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsNotification:

For each facility intending to operate under the provisions of this Air General Permit, the responsible official must complete and submit Part III of this Perchloroethylene Dry Cleaner Air General Permit Notification Form [DEP Form No. 62-213.900(2), F.A.C.] to give notice to the Department of intent to use such permit.

24Perchloroethylene (PERC) Dry Cleaning - Rule RequirementsAdministrative Corrections:

Any change in name of the responsible official or facility address or phone number;

A change in facility status requiring more frequent monitoring or reporting by the responsible official from that noted on the most recent notification form; and

Any other similar minor administrative change at the facility.

Violation of Permit.

This Air General Permit is valid only for the specific activity indicated.

Any deviation from the specified activity and the conditions for undertaking that activity is a violation of the permit

Violation of the permit constitutes grounds for revocation

Initiation of enforcement action

No revocation shall become effective except after notice is served by personal service, certified mail, or newspaper notice

Perchloroethylene (PERC) Dry Cleaning - Rule Requirements25Nullification of Eligibility. Eligibility for use of a this Air General Permit is automatically nullified by:

Submission of false or inaccurate information in the notification form for use of the Air General Permit or in the required reports;

Refusal of lawful inspection by Department staff;

Failure to submit operational reports or other information required by the Air General Permit; or

Failure to timely pay the required fee, penalty, or interest.

Perchloroethylene (PERC) Dry Cleaning - Rule Requirements26

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General Conditions [Rule 62-210.310(3), F.A.C.]

The duration of this general permit is five years. No later than 30 days prior to the fifth anniversary of the filing of intent to use this general permit, the responsible official shall submit a new notice of intent which shall contain all current information regarding the facility. The general permit is not transferable and does not follow a change in ownership of the facility. Prior to any sale, other change of ownership, or permanent shutdown of the facility, the responsible official shall notify the Department.Perchloroethylene (PERC) Dry Cleaning Part II - Rule Requirements

28The responsible official shall make every reasonable effort to conduct the specific activity authorized by this general permit in a manner that will minimize any adverse effects on adjacent property or on public use of the adjacent property, where applicable, and on the environment, including fish, wildlife, natural resources, water quality, or air quality.

PERC Dry Cleaning Part IIGeneral Conditions [Rule 62-210.310(3), F.A.C.]

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The responsible official shall allow a duly authorized representative of the Department access to the permitted facility or activity at reasonable times to inspect and test, upon presentation of credentials or other documents as may be required by law, to determine compliance with this Air General Permit and Department rules.

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Monitoring and Related Recordkeeping and Reporting Requirements.

The responsible official shall maintain records of monitoring information that specify the date, place, time, and operating conditions of measurement; the methodology used; the company or entity which performed the monitoring; and the analytical results. These shall include all calibration and maintenance records, original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit.

32PERC Dry Cleaning Part IIGeneral Conditions [Rule 62-210.310(3), F.A.C.]

The responsible official shall retain records of all monitoring data and supporting information for a period of at least five years from the date of collection.

33Title 40: Protection of the EnvironmentPART 63NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES (40CFR63)63.320 Applicability(a) applies to operatoring dry cleaning facility using perc(b) The compliance date for a new dry cleaning system depends on the date that construction or reconstruction commences.

34Title 40: Protection of EnvironmentPART 63NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES63.322Standards

The owner or operator shall close the door of each dry cleaning machine immediately after transferring articles to or from the machine, and shall keep the door closed at all other times.

The owner or operator of each dry cleaning system shall operate and maintain the system according to the manufacturers' specifications and recommendations.

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Title 40: Protection of EnvironmentPART 63NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES

63.322Standards Continued

The owner or operator of a dry cleaning system shall inspect the system weekly for perceptible leaks while the dry cleaning system is operating. Inspection with a halogenated hydrocarbon detector or PCE gas analyzer also fulfills the requirement for inspection for perceptible leaks. The following instrument is used to inspect the drycleaning system:

36Perc Detector

63.322Standards Continued(1) Hose and pipe connections, fittings, couplings, and valves;

37Title 40: Protection of EnvironmentPART 63NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES

(2) Door gaskets and seatings;(3) Filter gaskets and seatings;(4) Pumps;(5) Solvent tanks and containers;63.322Standards Continued

(6) Water separators

(7) Muck cookers

(8) All Filter housings

(9) Exhaust dampers

(10) Diverter valves

(11) Stills

38Title 40: Protection of EnvironmentPART 63NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SOURCE CATEGORIES

39What are the Reporting & Recordkeeping Requirements?

40What are the Reporting & Recordkeeping Requirements?

INSPECTIONS :If you buy 140 gallons or more of PERC per year, you must check your machine weekly for leaks and record the results.If you buy less than 140 gallons of PERC per year, you must conduct and record leak inspections at least every other week.Record the results of the inspections on the calendar. If leaks are found, they must be repaired within 24 hours. Indicate in the DATE REPAIRED block when repairs are completed. If parts must be purchased, indicate the dates they are ordered and the date installed. Parts must be ordered within 2 working days of leak detection and installed within 5 working days of receipt.

4163.324Reporting and recordkeeping requirements.

http://www.dep.state.fl.us/air/emission/sbeaplib/dry_cleaner_2010.pdf


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What are the Reporting & Recordkeeping Requirements?

If the facility installs new process or air pollution control equipment, alters existing process or control equipment without replacement, or replaces existing process or control equipment with equipment substantially different than that noted on the most recent registration form, the owner or operator shall submit a new and complete AG permit registration form with the appropriate AG permit processing fee of $100.00 to the Tallahassee addresses listed later in the presentation.

47What if I Change or Modify Equipment Rule 62-210.310(2)(e), F.A.C.?Submitting your Registration Form for OVERNIGHT DELIVERY: (FedEx, UPS, DHL, etc.)

FDEP 3800 COMMONWEALTH BLVD, MS-77TALLAHASSEE, FLORIDA 32399

48What if I Change or Modify Equipment Rule 62-210.310(2)(e), F.A.C.?for regular USPS MAIL DELIVERY: (U.S. Mail)

FDEP RECEIPTSPOST OFFICE BOX 3070TALLAHASSEE, FLORIDA 32315-3070

49Need Additional Information? Marnie BrynesDivision of Air Resource Management Air General Permits Program (850) [email protected]

orStephen McKeoughSmall Business Environmental Assistance ProgramOmbudsman1-800-722-7457 or (850) [email protected]

50Need Additional Information? http://www.dep.state.fl.us/southwest/contacts/

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Any Questions, Comments?

DEPs website www.dep.state.fl.us/air

The Small Business Environmental Assistance Program (SBEAP)

http://www.dep.state.fl.us/air/emission/sbeap/sbeap.htm

Stephen McKeough, Division of Air Resources Management SBEAP Ombudsman

The Title V yearly statement of compliance forms are not going to be required when the TV GPs are moved into Non TV GPs. If the NESHAP requires some frequency of compliance reporting, that will still be required.

News From Tallahassee52

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There are no more annual fees for these facilities. The last annual fee was billed in December 2006 with a payable date in March 2007. Once the rule is finalized the $100 registration fee will apply.


we are anticipating the rule revisions to be final sometime in the 1st quarter of 2011.


Questions

Questions

Questions

Thank you..5657

Documents

Florida Department of Environmental Protection